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DOTZON comments on GAC Safeguard Advice

  • To: <comments-gac-safeguard-advice-23apr13@xxxxxxxxx>
  • Subject: DOTZON comments on GAC Safeguard Advice
  • From: "Katrin Ohlmer" <katrin@xxxxxxxxxx>
  • Date: Tue, 14 May 2013 18:01:14 +0200



few countries around the world rate consumer choice higher than consumer
protection and public interest issues. On the contrary, most countries
around the world value consumer protection and public interest higher than
consumer choice, if necessary. Consumer protection laws all over the world
are designed to ensure the rights of consumers as well as fair trade
competition and the free flow of truthful information in the marketplace.
The global association Consumers International ranks “To be given the facts
needed to make an informed choice, and to be protected against dishonest or
misleading advertising and labeling” among the basic consumer rights. We
believe that even in countries where enforcing safeguards may be
challenging, those safeguards should be kept to secure trust of consumers in
the Internet. We believe that all new gTLD applicants support this goal and
are more than willing to contribute to a safer and more trustworthy Internet
than today. Therefore we strongly recommend to stick to the established
principles of public interest and consumer trust.


We would like to remind ICANN of the scope of the New gTLD program, where
all business models, including single registrant models, limited or
restricted registrations as well as an open model are all welcomed: “The new
gTLD program will create a means for prospective registry operators to apply
for new gTLDs, and create new options for consumers in the market”.
Especially for community-based TLDs a dedicated process with definitions,
criteria and processes has been established with the goal of promoting
access for restricted groups (communities) on the Internet. The Applicant
Guidebook encouraged Applicants “to identify possible regional, cultural,
property interests, or other sensitivities regarding TLD strings and their
uses before applying and, where possible, consult with interested parties to
mitigate any concerns in advance.”


We believe that the implementing the GAC Advice on several issues is not
only necessary but crucial to the success of the whole new gTLD program, the
reputation and responsibilities of ICANN to maintain the security and
stability of the Internet. DOTZON believes that the following GAC Advice
elements are particularly important:

- Since the application window closed, ICANN implemented several mechanisms
that affected all applicants including the Priority Draw, the Public
Interest Commitment and the latest RPM/TMCH specifications. According to the
guidebook any changes that have material implications to applicants should
be mediated between ICANN and the affected applicants.

- While the new gTLD program is intended to promote consumer choice and
competition, it also includes special provisions for delineated communities:
„a community-based gTLD is a gTLD that is operated for the benefit of a
clearly delineated community.“ and gives those community application clear
preference before standard applications. 


- Such preference clearly corresponds with §4 of the Affirmation of
Commitments which asks ICANN “to ensure that its decisions are in the public
interest, and not just the interest of a particular set of stakeholders


- It is thus a core element of the New gTLD Program to encourage community
applications in order to create trustworthy name spaces for Internet users
worldwide. Safeguards in place for these Community-based name spaces can be
enforced by the implementation of eligibility, abuse and enforcement

Nevertheless we are aware that some elements of the GAC Advice need to be
more specific both with regard to the strings that they are targeted at and
with regard to their real life practicability. Some other elements of the
GAC Advice seem to go beyond the GAC’s mandate within the multi-stakeholder
model of ICANN and thus must be dealt with in the proper policy development
processes of this model.


Thank you for the opportunity to comment.


Kind regards,


Katrin Ohlmer

DOTZON GmbH - incubating name spaces
Akazienstrasse 2
10823 Berlin
Deutschland - Germany
Tel: +49 30 49802722
Fax: +49 30 49802727
Mobile: +49 173 2019240

Registergericht: Amtsgericht Berlin-Charlottenburg, HRB 118598
Geschäftsführer: Katrin Ohlmer
Sitz der Gesellschaft: Akazienstrasse 2, 10823 Berlin

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